Memo Detail

Full Document:PDF Link
RCRA Online Number: 14959
Title: Compliant Management Options for Healthcare Facilities Impacted by the Temporary Hazardous Waste Incinerator Backlog
Document Date: 2023-03-10
To: Bury
From: Young
Organization of Recipient: ProMedica Health System
Description: EPA responds to a request it received to allow incineration of hazardous waste pharmaceuticals in the four types of non-hazardous waste incinerators listed in § 266.506(b)(3), as a way to mitigate challenges posed by the temporary backlog of containerized hazardous waste destined for incineration. In the response, EPA 1) Reiterates that only hazardous waste pharmaceuticals that are also Drug Enforcement Administration (DEA) controlled substances are eligible for the conditional exemption in § 266.506(a)(1) and may be incinerated in those four types of non-hazardous waste incinerators. All other hazardous waste pharmaceuticals are prohibited from being combusted at these non-hazardous waste incinerators. 2) Clarifies that healthcare facilities not operating under subpart P may use existing flexibilities to mitigate temporary waste management challenges, including VSQG off-site consolidation under subpart P, which does not require the receiving healthcare facility to be an LQG. 3) Encourages healthcare facilities that foresee difficulty complying with accumulation time limits to contact their state environmental agency or EPA Region as soon as practicable. (SEE ALSO: Memo, Hoskinson to Division Directors; August 10, 2021 (RO 14939).
Regulatory Citation(s): 262.14, 266.504(b), 266.506
Official ORCR Policy: Yes
Associated Topic(s): Burning, Combustion, Combustion of Hazardous Waste, Compliance, Disposal, Generators, Hazardous Waste, Incineration